Complaints processing and dispute resolution policy

The purpose of this policy is to ensure thefair handling of complaints and disputes received from our clients.This policy is intended to provide a framework for:

·      Establishing a free,accessible, and easy-to-use complaint handling service for our clients;
·      Providing clients withinformation to help them understand how we process their complaints;
·      Managing complaints fromreceipt through to resolution. It also aims to contribute to the continuousimprovement of our services by enabling us to identify common causes ofcomplaints and implement solutions to address recurring issues.

‍WHAT WE CONSIDER A COMPLAINT

‍A complaint is an expression of dissatisfaction or a reproach from aclient regarding the services or products we offer, together with anexpectation that we will take action to address the issue. For example, aclient may expect compensation, an apology, or corrective measures to remedy orstop the situation that gave rise to the complaint.

Certain communications are not considered complaints

The following examples are not complaints:

·      A request for informationor documentation regarding a product or service offered;
·      A claim for compensationor an insurance claim;
·      A request to correct anadministrative error, such as a transcription error or an error in thecalculation of an amount due; ·      A request to access oramend personal information;
·      A comment or observationabout our organization.

Please note

However, we consider a request to correct an administrative error to bea complaint when that error results in additional consequences for the clientor for several clients. For example, this would be the case if the errorresulted in fees that must be reimbursed to the client(s).

‍PERSON RESPONSIBLE

‍The person responsible for the application of this policy is JenniferBourré, Vice-President Training and Compliance.

‍Our Complaints Officer ensures the fair treatment of complaints receivedand oversees compliance with and implementation of this policy within the firm,including ensuring that:

·      Management and staff are aware of and apply this complaint handling policy;  
·      Clients can easily obtain information regarding how complaints are handled or about the status of their complaint;  
·      Staff carry out the follow-up required for the proper handling of client complaints;
·      The person assigned to handle a complaint possesses the skills and knowledge required to do so;  
·      Each complaint is handled objectively and with due consideration for the client's interests.    

‍COMPLAINT HANDLING PROCESS

‍We handle each complaint objectively while considering the interests ofthe client who submitted it, and we communicate with clients in clear andsimple language.

Clients may contact us at any time to obtain information about ourcomplaint handling process, to submit a complaint, or to inquire about thestatus of a complaint.

You may submit your complaint using the method most convenient for you. You may also complete the complaint form available on the website of the Autorité des marchés financiers (AMF). We can assist you in formulating your complaint.

‍Contact Information

‍To contact us or to obtain information regarding our complaint handling process:

·      By mail : 201-1955 Chemin de la Côte-de-Liesse, Montréal,Quebec H4N 3A8
·      By telephone : 514-447-7997 ext. 306
·      By email: plaintes.complaints@assuruni.com

‍Determining whether a communication is a complaint

‍When a client expresses dissatisfaction or a reproach, we determinewhether the communication constitutes a complaint. We consider all informationprovided by the client in making this assessment. If there is uncertainty, wewill contact the client to better understand the situation and determinewhether a complaint is being made.

We are responsible for helping clients clearly formulate theircomplaints, including by asking questions to better understand the situation.We also ensure we understand the client's expectations, such as whether theyare seeking a correction, reimbursement, apology, or other remedy.

‍Complaint intake

‍Each complaint is recorded in our complaint register upon receipt.

We ensure that complaints are acknowledged promptly and handled asquickly as possible.

‍Acknowledgement of reception

‍We acknowledge receipt of the complaint in writing within 10 days andinform the client of their right to have their complaint file examined by the AMF.

We also provide information regarding the expected timeframe for ourresponse and how to obtain updates regarding the handling of the complaint.

‍Documentation of complaints

‍A file is created for each complaint. We ensure that the complaint fileremains current and contains all relevant documents and information collectedthroughout the complaint handling process.

Complaint files are retained for the same period as client files and inaccordance with our Privacy Policy. 

‍COMPLAINT ANALYSIS

‍Understanding the complaint and the client's expectations

The person responsible for analyzing the complaint must obtain allinformation necessary to assess it. This may include contacting the client for additionalinformation or requesting documents and information from staff members orrepresentatives involved.

‍Final written response

‍We provide a final written response within 60 days.

We may provide one of the following responses:

·      We agree to the client'srequest and propose corrective action, reimbursement, an apology, or anotherappropriate remedy;
·      We propose a solutionthat partially satisfies the client's request or differs from the requestedremedy, with the goal of reaching a mutually acceptable resolution;
·      We reject the complaintif, following our analysis, we determine that it is unfounded or that noresolution is possible.

Our response explains how the complaint was analyzed, the factors thatled to our conclusion, and any proposed resolution. We also remind the clientof their right to request that the AMF review their complaint file.

The issuance of our response does not end communications with theclient. We continue to respond to inquiries, comments, and any new relevantinformation related to the complaint.

Extension of the response period

In some cases, the person handling the complaint may determine thatadditional time is required due to the complexity of the matter. Any extensionmay not exceed 30 additional days.

Examples of circumstances that may justify an extension include:

·      Delays caused by factorsbeyond our control, such as waiting for documents from a third party;
·      Exceptionalcircumstances, such as a significant increase in complaint volume following anatural disaster.

In such cases, the client will be notified in writing no later than thedate on which the response was originally due.

‍Evaluation of settlement offers

‍When we propose a resolution, we provide the client with a reasonableamount of time to evaluate the offer. The timeframe will reflect the complexityof the matter and allow the client to seek advice before accepting, rejecting,or making a counteroffer.

Once an agreement is reached, we have 30 days to implement it unlessanother timeframe is agreed upon and is in the client's interest.

We never require a complainant to withdraw another complaint as acondition of settlement. Furthermore, settlement conditions will never preventa client from:
‍
·      Requesting a review oftheir complaint by the AMF;
·      Contacting the AMF, theChambre de la sécurité financière, the Chambre de l'assurance de dommages, orthe Canadian Investment Regulatory Organization (CIRO).

‍REVIEW OF A COMPLAINT FILE BY THE AMF

‍Clients have the right to request that their complaint be reviewed bythe AMF if they are dissatisfied with the way we handled their complaint orwith our response.

Clients may request that we transfer their complaint file to the AMF ormay contact the AMF directly. In either case, we will transmit the complaintfile within 15 days of receiving the request.

‍SIMPLIFIED PROCESS FOR CERTAIN COMPLAINTS

‍Certain complaints may be handled through a simplified process where weare able to provide a satisfactory resolution within 20 days.

A complaint is considered resolved to the client's satisfaction when theclient accepts the proposed solution or when the explanations providedsatisfactorily address the concern.

Under this process: complaints may be handled by a member of ourcustomer service team. A written acknowledgement of receipt and a formalwritten final response are not required. Communications may be conductedverbally, such as by telephone.

For each complaint handled under this process, the individualresponsible must:

·      Inform the client of thereceipt of the complaint and the client's right to request a transfer of thecomplaint file to the AMF (within 10 days);
·      Provide the client withour response and proposed resolution (within 20 days).

These communications may be summarized in a document placed in thecomplaint file or fully documented within the file.

If we determine that the complaint cannot be resolved to the client'ssatisfaction within 20 days, we will notify the client in writing before theend of that period and continue the complaint under the standard complainthandling process.

‍OUR RESPONSIBILITIES

Representatives and employees

Any representative or employee who receives a complaint must promptlyforward it to the individuals responsible for complaint handling.

They must cooperate fully in the handling of the complaint and provideany documents or information necessary for its review.

Staff assigned to complaint handling

The individual responsible for handling a complaint must not do so ifthey are unable to remain objective.

They must ensure they possess the necessary knowledge and competenciesto handle the complaint and seek assistance where appropriate.

They are responsible for gathering information and documents necessaryfor the analysis of the complaint and may contact the client to obtainclarification regarding the circumstances giving rise to the complaint or theclient's expectations.

Management responsibilities

We ensure that this policy is communicated to all staff and thateveryone understands their responsibilities.

For example, all personnel who may be involved in handling complaintsreceive a copy of our complaint handling policy and procedures upon joining theorganization and are informed of any subsequent changes.

We establish the procedures and processes necessary to handle complaintseffectively and ensure that staff involved in complaint handling receiveappropriate training.

We appoint a Complaints Officer only after confirming that theindividual possesses the competencies required to fulfill the role.

We also ensure that management and staff cooperate fully in the handlingof complaints.